Details

Complex cross-border transactions often lead to prolonged Transfer Pricing disputes. Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), and Safe Harbour Rules provide mechanisms to achieve tax certainty, reduce litigation, and ensure fair profit allocation between jurisdictions.

We guide businesses through the complete lifecycle of APA/MAP applications and Safe Harbour compliance — helping minimize tax risk and ensure regulatory confidence.

Scope of Services

• Strategy development for APA, MAP, or Safe Harbour selection

• Preparation and filing of applications

• Representations with CBDT and foreign competent authorities

• Negotiation support and dispute resolution planning

• Compliance management for approved arrangements

Where It Helps

• High-value or complex international transactions

• Recurring TP disputes

• Significant cross-border service, finance, or trading activity

Documents / Inputs Required

• Historical financial and TP documentation

• Transactional data and FAR analysis

• Inter-company agreements and pricing models

Deliverables

• Filed APA/MAP application with supporting documentation

• Representation and follow-up until resolution

• Compliance framework post-approval